Submission Number: 560891-00290
Received: 9/9/2012 7:10:17 PM
Commenter: Erin Hicks
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
As a veterinarian, I'm concerned about the quality and safety of many OTC products that consumers may purchase. I have treated patients for OTC insecticide product (Hartz, etc) toxicity, including both products that were applied per the label directions and improperly administered products (e.g. dog product applied to a cat). I support stronger warning labels for OTC products as well as removal from the market of any product that has had a large number of documented significant side effects. How many more animals have to be poisoned by junk like Hartz?
I'm also worried about the growth of online pharmacies and "human pharmacies" marketing pet drugs. Most drug manufacturers insist that they do not distribute to these pharmacies and will not guarantee the safety or efficacy of these "gray market" products. Also, most "human pharmacists" are not adequately trained in the differences between humans and all other species. I know that the American Veterinary Medical Association and Washington State Veterinary Medical Association are investigating reports of pharmacists who have improperly filled or given incorrect medical advice to animal owners regarding prescription and OTC drugs. I can personally attest that my own pharmacist told me he had advised his brother of a specific OTC drug and dose to treat his dog's arthritis pain, not realizing that the drug in question is fatal to dogs.
I believe that veterinarians must offer written prescriptions upon request (and should display a sign in their lobby letting clients know that they are available upon request), but that we should be cleared from any wrongdoing should the client choose to fill the script at a pharmacy and the pharmacy makes an error (such as Franck's Compounding Pharmacy or a pharmacy substituting prednisone for prednisolone). I think any pharmacist that fills medications for non-humans must undergo classes in veterinary pharmacology so that they can adequately counsel consumers (since veterinarians usually perform this task at this time).
I do not agree with the recent proposed legislation that veterinarians would be forced to offer prescriptions to all clients, even if a client wants to fill the medication at the veterinarian's office. In my own state, we are required to purchase tamper-proof prescription pads that cost a good deal of money. If I had to offer a prescription for every medication for every patient (even when it wasn't desired by the client), my office's costs would go way up and we would have to charge clients for something that the script they currently receive for free. That isn't fair to vets or consumers.